At some point last winter, I noticed I couldn’t go anywhere without somebody asking me how they could leave the United States. It wasn’t that surprising. I’ve been writing about citizenship for years, Trump had just been sworn back into office, and I live in New York City. Anyone who’s met me also knows I just love to talk about passports.

I was a little unnerved, though, when I started overhearing random peoples’ conversations on the subject: their attempts to get a passport through a grandparent, or begging their boss for an overseas transfer. There were more exotic schemes, too, like “laundering” small sums though a retired relative to make savings look like passive income, or opening an LLC to employ oneself abroad, all to qualify for a European visa.

I heard these tips and tricks everywhere: dinner parties, the subway, my son’s pre-K field trips, and (naturally) at the Park Slope Food Co-op. At a café in Soho, I eavesdropped on a recent college graduate detailing a ploy to move to Spain forever to escape student loans.

Telling people about their passport options used to be my weird party trick. Now, the normies were doing it without me!

It was around this time that I reconnected with sources I met reporting my first book (somehow a whole decade ago). These sources, who help mostly wealthy people migrate, confirmed that what I was hearing was not just confirmation bias, but a real phenomenon. Since Trump’s first term, Americans had begun outnumbering their other clients by orders of magnitude.

National data helps back this up: Ireland naturalized 26,000 Americans in the first half of 2025, and in April the statistics office reported that the number of Americans moving there practically doubled in the previous 12 months. The UK has seem similar increases, and Americans are all over Lisbon and Porto and Berlin and Madrid. Anecdotally, they are also buying up apartments in Nice and Cannes, ruining the food in Mexico City, and, according to my British friends, filling up private schools in London with their children.

After I wrote an Atlantic article on plan B passports for Americans, I got a bunch of emails, but one in particular piqued my interest. It was about expatriation tours, which struck me as new ground for this sort of business. U.S citizens weren’t just making a backup plan; some were leaving for good, and an industry of sorts was popping up to help them figure out visas, logistics, and integration.

Obviously, I had to go on one of these tours. So in September, I packed my bags and traveled around Holland with GTFO tours, a relocation coaching company started by two vivacious American women, Bethany Quinn and Jana Sanchez.

On the trip, I got to know a group of people who really opened my eyes to how miserable Donald Trump is making ordinary U.S citizens. I also ate horrible Dutch food and caught a cold because it is never, ever the right temperature in Holland.

I wrote about my time with GTFO in this week’s issue of the New Yorker. It’s my first piece for a magazine I’ve been reading since I was a little kid. I’d love it if you read it and let me know what you think!

I’ve come to have a coffee with my mother at the Café du Théâtre when I notice the woman in the corner of the terrace. She’s dressed impeccably: beige slacks, white shirt, no bling. Fashion people call this “quiet luxury”, but it’s quiet only in the way that a dogwhistle is quiet. Linen, it turns out, can scream.

She’s in her sixties (quiet seventy); blond (quiet gray); and nervous, very nervous, obviously anticipating somebody’s arrival. Before her on the table are two glasses of citron pressé (quiet diet) and she is fidgeting with a watch or bracelet. Her eyes dart around. There’s something bothering her in her bag. She waits. Whatever’s going on, she wants it to end.

The coffee’s pretty good. I finish in fast. The woman sips her juice and looks at the second glass on the table. It’s glaring, conspicuous: three lemonsworth, freshly squeezed.

At last arrives a man. He’s tall, purple polo, pedo shades, earbuds. The kind of guy who never takes out his earbuds. Barrel chest, younger. Nothing quiet about him.

The man sits down next to her in the chair, which grates against the stone floor. His legs are too long, it’s not comfortable, and she’s twitching guiltily. They get closer to whisper things that I can’t hear. She’s obviously richer than him but he has a certain power: she needs him to solve a problem that she has. She touches him a few times on the arm. Her angst is overbearing.

Then begins business. She takes out of her bag two ordinary yellow envelopes and puts them on the café table. He removes from one envelope a thick wad of cash. As he thumbs the bills, which number the dozens at least, I can see from where I’m sitting that they are 1,000 franc notes. This makes them the world’s second most valuable kind of money, after a piece of paper from Brunei.

I have never had the pleasure with this particular denomination, but the Swiss National Bank reports that while these banknotes make up just 7 percent of bills in circulation, their value totals that of nearly half the existing cash. Many shops won’t accept thousands. You probably can’t use them to pay a mortgage or buy gas. This all suggests that their purpose is simple: to remain exactly what they are.

The CHF 1000 banknote, issued in 2019, is illustrated with a small globe and two hands shaking. That is also where this encounter is going. The man starts counting the money: straight up counting it like no-one’s watching, in broad daylight on the terrace of a café. He’s in his element. When he’s done counting, he puts the envelope in his briefcase, and his patron kisses his cheek with an odd tenderness. Then, he gets up and walks off. The woman softens. Visibly, a great weight has been taken off of her shoulders.

Her phone rings quietly in her handbag. She answers the call. It’s some business about a car in a garage, completely uninteresting, but her heart is so light that it sounds like she’s singing.

Then, the woman gets up and straightens her shirt. With her fixer’s forsaken citron, she approaches a table a few feet away, where a woman in her thirties has spent the length of the encounter obliviously toggling tabs on her laptop: on the one hand, a Petit Bateau sale, on the other, messages for her marketing job.

“It’s a citron pressé; nobody’s touched it,” says the older woman gently, leaning in.

“Have it. It’s refreshing.”

I got back on the passport beat recently for a story about how Americans have been buying more citizenships and residence permits than any other nationality. This was completely inconceivable a decade ago, when a U.S passport was considered among the safest and best in the world. 

I won’t rehash the whole thing—here’s a gift link for the Atlantic article—but there’s been some big news since it came out: the European Court of Justice ruled that Malta’s “golden passport” sales were illegal. This judgment came as a surprise, as the court’s advocate had previously advised the European Commission last year to back off.

The judgment is both a big deal and a small deal. Small because Malta only sells a few hundred passports a year and is presently the only European country to do so outright. Also small because there are conceivable ways to keep the racket going: from what I understand thus far, the court’s objection hinges on the lack of real-life ties the applicants have to Malta. There’s a clear scenario in which the ultra-rich can still have pathways to obtaining EU passports by investment (as they do in Portugal and other states) while Malta is “brought in line”, as it intends to. The applicants just have to move their asses, not just their assets—which for them is, well, a pain in the ass.

Still, let’s not downplay things. The case is a shock to the industry (I’m hearing reports of some VERY spicy group chats!) and potentially a turning point in the way we collectively think about citizenship moving forward. The past couple of decades have tested the limits of citizenship as an institution: who can have it, for what reason, in what circumstances, and even for how much money. It looked as though passports were taking on features of flags of convenience, but how brazenly they could be commercialized was a point of contention.

Now, it appears the limit, in Europe at least, has been reached. The historian Patrick Weil, who’s been a critic of these programs for over a decade and was consulted for the lawsuit, texted me this morning celebrating the judgment as a victory. He said: “the court declared that certain fundamental right cannot be commercialized. That is remarkable.”

The Commission put out a statement, too. “European citizenship is not for sale,” its spokesperson said. “Investor citizenship schemes breach EU law and as such should be abolished by all member states.” I bet they’re popping the champagne: the EC has wanted this for a very long time!

Zooming out, the case suggests the EU court believes the bloc gets to have some say in the naturalization policies of individual member states, and can mandate a legit “genuine link” to the country like real residency, rather than, say, a golf club membership and an empty rental unit. This is controversial: states don’t like being told what to do (remember Brexit?).

Henley & Partners, a big player in the industry, has put out a note criticizing it as "EU encroachment on national competence” and an attack on the sovereignty of individual states. If Malta can’t choose its citizens, the reasoning goes, is it even a sovereign state?

Interestingly—and paradoxically—if other countries tighten the screws on investor citizenship or do away with it entirely, political commentators will invariably take these moves as a symptom of “de-globalization” and a return to strong national borders et cetera—even though that’s the opposite of the supranational overreach the EU is being accused of. Here, the EU (a broadly “globalizing” entity) is pushing states to get in line with its idea of what European citizenship is, and in doing so, somehow hardening their borders, making them less “global”.

So which is it? Neither? Both? We are faced yet again with the logical conundrum at the heart of state sovereignty, which can take the form of both absolute autarky and an enthusiastic repudiation thereof; joining treaties and leaving them.

I’ve said before that for the purposes of understanding the world, “sovereignty” is not a very useful concept because everyone just takes it to mean what they want, especially these days (I had a brief fantasy of never using the S-word in my last book..) If you truly want to go down this rabbithole, here’s a lecture by Martti Koskenniemi that helped me makes sense of this by framing it as a problem of logic.

Subscribe now

After my Atlantic story came out, I heard from a bunch of people sharing more stories of plan B passports and expatriation. I don’t know that their (or their clients’) plans will necessarily be affected by the EU news, unless the Malta judgment is a sign of bigger things to come. I thought they were pretty interesting, so here are some of their observations:

1. The clientele for second passports is diverse

… in a DEI way. I’m only half kidding. A couple of citizenship consultants reported that they has multiple same-sex couples and transgender clients who feared for their future in the U.S and who were making moves to secure an exit strategy. Another expert told me that well-off Black Americans are considering buying Caribbean passports because of the decline of US civil rights. If you read the news, none of this should be particularly surprising. 

2. Relocation tours are gaining momentum

In the Netherlands, Panama, Costa Rica and Mexico, tour groups are catering to people looking for new homes abroad. There are specialized ones for Black expats in Panama (I heard from a local sea captain that the community throws the best parties!) and Americans in Amsterdam (a company called GTFO Tours, whose name is perfect, informed me that under the Dutch-American Friendship Treaty, US citizens can get residence permits by opening a business and investing just $4,500.) 

Not all of this is new—US and EU retirees have long moved abroad to lower costs and enjoy life—but this infrastructure seems to be expanding to accommodate younger people as well. These programs are unlikely to end because they involve people actually moving, even if there’s cash involved in the transaction.

3. Choose your next adventure

You can pay to take a quiz on Newroots to see what expatriation route is best for you. I got a complimentary report and based on things like income, family, languages and other preferences, it recommended I move to Portland, Montreal, Barcelona, Austin or Lisbon, in that order. I think I might have under-reported my seasonal depression in the survey. But the report was very well-considered and extensive otherwise and has loads of technical information on things like visas, schools, professional licensing, etc.

4. Americans are doing other weird visa stuff

David Lesperance, who I incidentally spoke to for my first-ever story on citizenship sales, sent me a playbook for Americans who don’t want to be citizens anymore (often because they don’t want to be taxed indefinitely on their worldwide income) but still want to come and go freely for family reasons or just because they <3 New York. These “itineraries” are complex and typically involve renouncing citizenship, establishing residence abroad, and obtaining a business-related visa to enter the States. The takeaway? Never, ever underestimate what a rich person will do to avoid taxes!

5. Fool’s Gold

The Trump administration claims it has sold boatloads of Gold Cards even though there are no official channels through which to obtain them. Nobody I’ve heard from has begun a transaction of this nature. I look forward to the day I can talk to a real, live Gold Card applicant. If you are one, you can e-mail me anytime!

My second excuse for posting infrequently is that I don’t like to be repetitious. Then, I was reminded by my friend Mark Greif that it’s okay for journalists to peddle the same story a dozen times, because it’s the only way to do it and frankly, no-one cares.

To that end, I wanted to call your attention once again to Foreign Trade Zones, a quirk in US customs law that’s suddenly become more appealing in light of “Liberation Day”—aka, Trump’s tariffs—that may (or may not?) take place tomorrow.

For newbies, FTZs are carveouts where tariffs temporarily or conditionally don’t apply. I wrote about them for this newsletter after watching Tenet a couple of years ago. Apparently, trade jargon can help you make sense of Christopher Nolan movies when nothing else can.

FTZs exist all around the world in different configurations—warehouses, fenced-off areas, office parks, actual ports—and they are mostly uncontroversial, like globalist IKEA. As it so happens, the Swedish company participated in a for-profit initiative to employ Syrian refugees in a Jordanian special economic zone that was granted special EU import concessions in exchange for said employment. The results were not particularly inspiring.

In the US, these special areas (of which there are hundreds around the country) let companies either store imported products without paying customs fees, or allow them to manufacture products they can later import, perhaps at a lower charge. They’re a nice little hack for companies dealing in foreign goods they don’t immediately need to offload.

So it’s not surprising that the companies operating these zones are suddenly being inundated with calls from businesses that see them as a potential workaround for Trump’s impending tariffs. Even the industry’s trade conference in May is looking at record attendance. I want to go!

“Trump’s more rapid rollout of trade restrictions through executive orders is prompting businesses to seek ‘more flexibility and control’ by stockpiling goods at risk of being caught,” writes Oliver Telling in the FT. “These goods included car parts, pharmaceutical products and air conditioning units, the executive said.”

“Ahead of the ‘liberation day’ tariffs, one logistics executive said he was ‘confident that [carmakers] will be assessing’ whether they can get authorisation to manufacture in foreign trade zone” Telling goes on, concluding that a zone boom (or boomlet) may well be ahead. (Special thanks to David Smith for sending me the link!)

It sounds like these stockpiling plans are tentative at best—the way he’s carrying on, little would stop Trump from altering the rules of FTZs if he didn’t like what went on in them. But the resurgence of interest in them makes sense given how hairy things are out there, and also how FTZs began in the first place.

The legislation that established them came out of the ultra-protectionist Smoot-Hawley tariffs, which battered American trade nearly a century ago. Back in 2018, I made a short radio segment for Marketplace on the old tariffs and the appeal of FTZs with Dara Orenstein, the author of a great book on the subject whose other work inspired one of my book chapters. As she put it: “Protectionism is great for business for foreign trade zones.”

The tariff-to-zone pipeline is a pretty good example of my concept of “national globalism.” It squares with what I think will happen in the years ahead: Trump will bring offshore back onshore without undoing all the damage that offshore has wrought.

It also shows how nationalism creates new, weird and mutant forms of globalism—sometimes in your own backyard!

On a different topic, I laughed out loud at this post. I’m assuming it’s an April Fool’s joke, but if it’s not, I might have to organize a new family vacation. Taiwan to Prospera is one hell of a journey…

These images, depicting the physical hidden globe, are by the artist Ingo Gunther. Gunther uses data “to show what the world is like (beyond the geography provided on globes) and to give a useful sense of proportion and dimension.” His work is terrific. You can find more of his visualizations here.

Hello subscribers old and new!

It's been two weeks since The Hidden Globe came out, and the reviews have been incredible.

In The New Yorker, Gideon Lewis-Kraus describes the book as “a vivid, revelatory, and politically unpredictable tour of this present-day network state” and goes on to discuss how it relates to projects like Balaji’s Network State, which is currently hosting a pop-up in the failed Forest City compound in Malaysia. This is the kind of review authors dream of, so I urge you to read the whole thing. And if you are attending Network State U and want to tell me about it—or if you want to organize an event, podcast, reading, or just chat—drop me a line!

In The Washington Post, Jordan Weissman notes that the book made him think of Donald Trump’s economic policy in a new light. “The former president has said he intends to build a ring around the country with punitively high tariffs while carving out his manufacturing zones. In doing so, he’d essentially reverse-engineer the United States to look more like the kinds of desperate, developing economies that have historically traded a bit of their sovereignty away in the name of growth.”

The New Republic has named The Hidden Globe one of the season’s best books. I did interviews with Josh Keating at Vox and Tyler McBrien for Lawfare’s podcast. I also went on Bloomberg’s Odd Lots to talk to Joe Weisenthal and Stacy Alloway about the parallel worlds of the ultrarich.

If you’re quick on your feet (or fingers, I supppose) you can still tune into my conversation with Ben Mauk for New America at noon EST on Tuesday, Oct 22 (an hour from when this message hits your inbox.) RSVP here!

And finally, if you happen to be in Providence, RI, I’ll be at Symposium Books on Nov 21 at 6PM with The Dig’s Daniel Denvir.

With that out of the way, I wanted to point you to an interesting bit of news from the world of weird jurisdictions. It happens to involve one of my favorite places I’ve never been to: Mauritius!

Earlier this month, the British government announced—after decades of waffling—that it would formally transfer sovereignty over the Chagos archipelago to Mauritius. This is a big deal for the Chagossian people, who were violently forced off the islands between 1967 and 1978, have been fighting to return since, and after a drawn-out series of legal battles, may now have the chance to finally go home. The jurist and author Philippe Sands represented the Chagossians in court; his book, The Last Colony, tells the backstory, and also contains what I can only describe as international law gossip. IYKYK.

The decision’s a big deal for Mauritius, and the world, on a political level, too: when the British pulled out of Mauritius in the sixties, they kept a smattering of islands for themselves so that they could make good on their covert agreement with the U.S to lease them the island of Diego Garcia for use as a military base. They classified this area a British Indian Ocean Territory, or BIOT.

The whole thing was unbelievably sketchy—even Adam Curtis could not have made it up—and the result was that while Mauritius became independent, Chagos became the Indian Ocean’s answer Guantanamo Bay: taken from one country, leased out piecemeal by another, and later used as an alleged black site from which the Iraq War was launched.

More recently, Diego Garcia made news when a group of Sri Lankan asylum-seekers arrived there by boat. Their case was made more complicated by the fact that for a time, the US (the tenant) was not letting lawyers from the UK (the landlord!) hold a hearing about their unlawful detention in a British Indian Overseas Territory (BIOT) Court.

Now that they’re out of the picture, the Brits are offering some of the migrants the chance to settle in a transit center in Romania before possibly admitting them to the U.K. Others have had their asylum claims rejected. A few wound up in Rwanda for medical treatment. And some stayed on Diego Garcia, which the U.S continues to use as a military base.

I’m not dizzy; you’re dizzy.

Share

In The Hidden Globe, I write about how Australia “excised” parts of its territory to get away with what amounted to human rights abuses and breaches of domestic and international law in its treatment of refugees. Mauritius underwent its own “dismemberment”, but at the hands of its colonizer.

I find it interesting to note that “dismemberment” is the UN’s term for it, while “excision” is the Australian government’s.

This is the difference between an appendectomy and a nose job.

Share Terra Nullius

Meanwhile, tech observers are worried about the future of another kind of sovereignty: the popular .io domain, which, like the BIOT, was (nominally) under British jurisdiction. But what happens to the domain when the BIOT ceases to exist

As Gareth Edwards writes in Every:

“Various international bodies will update their records. In particular, the International Standard for Organization (ISO) will remove country code “IO” from its specification. The Internet Assigned Numbers Authority (IANA), which creates and delegates top-level domains, uses this specification to determine which top-level country domains should exist. Once IO is removed, the IANA will refuse to allow any new registrations with a .io domain. It will also automatically begin the process of retiring existing ones. (There is no official count of the number of extant .io domains.)

Officially, .io—and countless websites—will disappear. At a time when domains can go for millions of dollars, it’s a shocking reminder that there are forces outside of the internet that still affect our digital lives.”

Subscribe now

Dearest subscribers: the season of shameless self-promotion is upon us (well, me.) The Hidden Globe will be published next Tuesday, October 8!

Would you consider putting in a pre-order? I don’t (and won’t) charge for this newsletter—but I would love to keep doing what I’m doing, and buying my book is the #1 way you can help.

Pre-ordering will guarantee that you get the book on time, and good numbers will mean I get proper attention from bookstores and the media. You can also ask your local bookstore to make sure they have copies on pub date, and request that your library stock it, too. Thank you!

If you read Terra Nullius, you probably have a good idea of what the book’s themes are. Now, you can also read an excerpt of a chapter about Dubai in The Atlantic.

A lot of people love to hate Dubai, but when I went in November 2021, I had a great time: being from Geneva, I always feel at home in cities where a large portion of the population is from somewhere else, and there was something cozy about how casually people on the street or in the metro would ask, “where are you from?” (a question that, for valid Trumpian reasons, has gotten a little un-PC in the U.S!) When I wasn’t schlepping around the DIFC compound or the Expo fairgrounds, I was hanging out in a mall with a taxidermied falcon.

Back to book business! I have some great early reviews and events to share.

BOOK TOUR

Next Tuesday, Oct 8 at Greenlight Bookstore in Brooklyn, I’ll be talking to Bloomberg’s Max Abelson about my reporting. The event starts at 7:30 and we’ll go across the street to Fritz for drinks afterwards. I hope some of you can make it!

On Tuesday, Oct 22 at 12:00 noon New America is hosting an online panel for me with my friend and colleague Ben Mauk. If you happen to live in one of the jurisdictions I write about, this is your chance to tune in!

On Monday, November 25 at 7pm, I’ll be reading at Solid State Books in Washington, DC.

And on Tuesday, November 26 at 7pm, I’ll be reading at Red Emma’s in Baltimore.

Stay tuned for more events in Boston, Providence, at The Remarque Institute, at the American Historical Society, and beyond!

I genuinely love public speaking, so if you’d like to set something up at a bookstore, event venue, university, or workplace, drop me a line and we’ll figure it out.

Subscribe now

In the meantime, I’ve allowed myself to share some praise for The Hidden Globe from some people and publications I really admire. Early reviews have been great—the Minneapolis Star-Tribune called The Hidden Globe “luminous” and Publisher’s Weekly said it was an “impressive achievement.”

I hope you all read it and feel the same way!

Praise for THE HIDDEN GLOBE

“You might think a history of tax havens would be dull but ‘The Hidden Globe’ is luminous….A brilliant expose of international tax havens reveals how the ruling class shapes our world…In her stellar work of literary journalism, Atossa Araxia Abrahamian peels back murky history and legalese to expose the machinations of these enclaves, how they thrive beyond the reach of laws, sovereign unto themselves. Come for Switzerland, stay for Singapore — the sun never sets on this grift… ‘The Hidden Globe’ could easily have been a litany of malfeasance and wonky woes, and still contributed to debates surrounding equity and the future. Abrahamian’s artistic touch imbues the dry bits with shine and movement. She peoples her narrative with the famous and infamous, cameos from Mary Shelley and Che Guevara to Etienne Schneider, Luxembourg’s former deputy prime minister…A season of unrest looms ahead, and ‘The Hidden Globe’ lays out the unvarnished truth in a luminous feat of reportage.” – Minneapolis Star-Tribune

“There are the maps of the world that everyone knows. The images of the world with borders, oceans and seas, cities and towns. And then there are the maps of the world that few will ever see—the complex world of free trade zones and freeports, flags of convenience and extraterritoriality. Atossa Araxia Abrahamian explores this ‘counter–geography’…which looks to expose the way in which wealth flows around the world outside of the public’s view.” – Diplomatic Courier

“Sharply observed… Abrahamian unravels the opaque world of ‘special economic zones’ and other places…where national and economic boundaries are blurred… Abrahamian also considers trendy concepts like ‘charter cities,’ noting, ‘To cede this territory to rigidly ideological capitalists alone would be a big mistake.’…Her well-researched, engrossing work manages the minutiae of several fields, including telecommunications, maritime law, and fine art, to stitch together a multilayered tale of how privilege works to protect itself. Important documentation of how mechanisms favored by the 1 percent increase global inequalities.” – Kirkus

“A revelatory look… Abrahamian begins by delving into the histories of contemporary tax havens…but her scope is far broader… Providing poetic insight…Abrahamian, who perceptively analyzes these zones as neither ‘all good, nor all evil,’ but as ‘cracks’ that reveal how the world really works. It’s an impressive achievement.” – Publishers Weekly, Starred review

“Fascinating—reads like a novel yet packs a policy punch for anyone interested in global migration, licit and illicit corporate networks, legal fictions and realities, and the ongoing mutation of the nation-state. Read it, share it, and above all, reflect on the paradox that while we grapple with how to exert physical control over the digital world, we ignore the creation of vast new legal and physical spaces in plain sight.” – Anne-Marie Slaughter, CEO, New America, and Professor and Dean Emerita, Princeton University

“The Hidden Globe eloquently verifies a long-inarticulate suspicion: that our world has been invisibly remade. Traveling to different parts of the world, Abrahamian describes insidiously interconnected global regimes of inequality and injustice. In the process, she boldly renews our sense of reality and brilliantly illuminates our political impasse.” – Pankaj Mishra, author of The Age of Anger

“Although we imagine the world as divided neatly into nation-states, it is in fact strewn with loopholes, islands, freeports, and zones where the usual laws don’t apply. Such places matter enormously. Abrahamian is the ideal guide—fluid, sharp-eyed, and thoughtful—to this hidden landscape.” – Daniel Immerwahr, author of How to Hide an Empire

Last week, Joe Biden passed an executive order that makes it much easier for the U.S to send asylum-seekers back to their country of origin with virtually no questions asked.

It’s technically not an outright ban on asylum—the order applies only in periods when more than 2,500 people attempt to cross over into the U.S per day. Not is it indefinite: once daily “encounters” dip below 1,500 per day, the rule will no longer apply. But the former threshold has been consistently exceeded for years, so for all intents and purposes, it just got a lot harder for people to come, and even harder for them to stay, even if they are likely to face serious danger back home.

Biden’s order is unequivocally awful, but it’s not all that surprising. What’s more surprising is the eagerness of certain people in my profession to buy into the language and logic of this shadow-ban on asylum, and in particular to casually use the term “loophole” to describe what asylum claims have become. The word has turned up in headlines; it’s also been invoked by columnists like Nick Kristof (who claims to otherwise support refugees.) Molly O’Toole, an excellent immigration reporter, called this tendency out as “irresponsible.” Trust her—she won a Pulitzer!

I’m not a language purist by any stretch—I appreciate that the usage and meaning of words can change (I draw a hard line at “impactful.”) But I have thought a lot about loopholes and immigration and the logic that makes the nation-state system function, and to describe asylum as a loophole is missing the point.

It is true that “loophole” is a slippery term, much like its cousin, the legal fiction. But this is intentional: the ambiguity speaks to the essence of the term itself. The whole point of a loophole is that it seems like it shouldn’t exist, but does. Usually, the loopholes carries with it the whiff—however faint—of corruption: closer to “not illegal” than to “perfectly legal”. And yet it is legal, at least for the moment.

The loophole appeals to our sense of justice: no matter how permissible it is, it does not feel entirely fair.

Subscribe now

A super-egregious loophole might look like this: an exemption for companies with exactly 3,582 employees and 23 contractors plus one (1) office cat from having to offer health insurance to their workers. (To be clear, I made this one up.) Could there hypothetically be many, many companies with this exact human and non-human headcount? Sure—in theory. But a loophole can be written to look as though it’s fair to all, when in fact, it plays favorites.

Most loopholes aren’t this glaring. They look more like the carried-interest loophole, that allows hedge fund executives to treat their income as capital gains rather than ordinary income, which is taxed at a lower rate. Carried interest is hated by many, yet lives on and on. That’s all thanks to aggressive lobbying.

It’s useful to keep these “maximum” loopholes in our minds when we think through what is not a loophole. In New York City, owners of expensive houses often pay less in property tax than people living in smaller co-ops or condos. This might look like a loophole conceived to benefit the rich, and in practice, that is overwhelmingly how it now functions. However, this particular rule was intended protect homeowners whose incomes did not keep up with rising real estate prices.

Has the tax become corrupted by the passing of time? Absolutely. Has it become akin to a loophole? One hundred percent. But was it conceived as such, with the intention to evade and elide? Not quite.

My unprofessional verdict? Not a loophole per se—but a hole nonetheless, and one that should be quickly re-sealed.

Share

So here’s where these real and imagined examples leave us. Loopholes are technically legal: either inscribed in, or conveniently omitted from, the rules. They follow the letter but not the spirit of the law, and usually for the benefit of rich men knocking at the gates of havens.

If we are to keep speaking Biblically, loopholes are needles for camels. They respond to contingencies, but are animated by something a little more absurd. Observed in action, loopholes thus elicit a unique emotional response: you aren’t sure whether to laugh or cry. (This is my baseline emotional state: an occupational hazard.)

Finally, intention matters: often, the key to determining what is and isn’t a loophole is to look at where it came from.

“Loophole” is a weird word: a sort of double-positive, and visually, almost tautological (I am thinking again of a thread, a needle—and a camel.) Etymologically, the term is curious, too. In the olden days, a loop-hole was a slit in the wall of a fort or a castle that allowed soldiers to shoot their arrows out of the fortification while shielding themselves from the enemy’s artillery.

This, I think, should be part of how we understand the loophole as a concept, especially in the context of immigration today. Because if we are thinking about a state, and the walls around it, and following the logic of the politicians who talk endlessly about migrant “invasions”, then both the architects and beneficiaries of the loopholes are not the people outside the gates, but those within.

Could a crack shot with a bow and arrow hypothetically slip one through? Yes, hypothetically. But the loop-holes are part of the castle wall: a wall designed to keep people away.

A loophole, then, is not a lifeline, or indeed, a means to asylum. It’s quite the opposite.

Share Terra Nullius

It’s worth remembering that it is exceedingly difficult to immigrate to the United States, even—especially!—if you are an asylum-seeker who has made it past a border checkpoint. Most asylum claims fail. Those that succeed are the result of months, even years of bureaucratic and legal wrangling. It’s costly, stressful, and time-consuming. There are no guarantees.

The whole point of a loophole is that it makes things easy, or easier: a kind of hack. If asylum were actually a loophole to living in the U.S, what does it tell us that it’s still so goddamn hard?

What it tells me is that calling asylum a “loophole” is just another way to stigmatize and delegitimize migrations: for now, the migrations of the poor, but before long, everyone else’s as well.

Because if asylum is a “loophole”, then so are all visas—fiancé visas, artist visas, CEO visas, guest-worker visas. There are few ways pathways into a fortress this dead-set on keeping people out. And there’s no shortage of arrows shooting out.

One of the biggest dilemmas I faced while writing The Hidden Globe was whether/how much/how the heck to write about Próspera, a semi-autonomous “charter city” or ZEDE on the Honduran island of Roatan.

The story was (and is) legitimately interesting to me: while it didn’t strike me as being as groundbreaking as boosters hoped and critics feared, it still hinted at the shape of new cities to come: carveouts within a state with their own rules, currency, and political culture. It was the most significant (and, arguably, only) development in the charter city universe: the enclave was about as devolved from national laws as you could get, and it had buy-in from the state, big-name Silicon Valley investors, and a cast of lesser-known but colorful characters. I’d certainly been covering it for long enough—it had been almost a decade—and I’d conducted more interviews than I can count.

But even in the best circumstances, it’s tricky to write about a fast-changing situation in a book that won’t be published for months and will (hopefully) be read for years to come. Próspera was made even more unpredictable due to the pandemic and the controversial political nature of the project.

I’d initially planned to travel to Roatan in late 2021, do my reporting, and write a relatively straightforward chapter on the ideas and people shaping Próspera—you know, the kind of thing you’d read in a mainstream magazine that contrasts foreign ideological masterminds with unhappy locals trying to maintain control over their land and way of life. I was six months pregnant with a toddler at home and the pall of Covid all around, but I’d pulled off a trip to Dubai the month prior and I figured this would probably be my last chance before I was too huge, too tired, and too busy to travel. Besides, what East Coaster can turn down a Caribbean beach in dreary December? Not me! So I found a translator, booked a hotel, and even bought plane tickets to fly there via Miami and Tegucigalpa.

Sadly, my beach trip was not to be, because in quick succession, two things happened. The Omicron variant of Covid-19 swept through the world, making travel and testing an annoying, risky ordeal. Then, the leftist Xiomara Castro won the presidential election in Honduras after having campaigned on an overtly anti-charter-city platform.

A week before my planned departure, I got in touch with my contacts at the Charter Cities Institute, whom I’d planned on shadowing with while they filmed a documentary. They confirmed that the trip was off. The pandemic was dicey—but the politics were downright hostile.

Since then, I’ve had to follow the charter city from afar (the actual chapter ended up taking another direction: to find out, you should pre-order my book). And although the Honduran Congress voted to partially nix the law allowing for this sort of free zone in late 2022, Próspera has hung in there, most visibly by getting a little weird and courting bio-hackers seeking experimental treatments they can’t get in the U.S.

Some medical tourists, including seasteading impresario Patri Friedman, got injections of follistatin, a gene therapy meant to enhance athletic performance (Friedman stopped the treatment to help test its reversability, but had only good things to say about it and plans on restarting when he can.) This led to the jurisdiction launching Vitalia, a “decentralized permanent city focused on accelerating the development of life extension technologies” (there is a joke, here, about death and taxes.)

Is this the Ayn Rand-worshipping, tax-evading, regulation-avoiding worse case scenario that some of us feared back in 2012, when the Honduran government approved the creation of semi-autonomous jurisdictions on the country’s soil? Not quite, though there is a lot of crypto (there is always a lot of crypto.) For now, it’s more of a playground than a snakepit, and it’s coasting on the appeal of these little perks and its beachside location. I expect more parties, experiments, and weirdness to come.

This isn’t to say it won’t get more serious. The jurisdiction says it’s raised $100 million, which in real estate terms is not a lot, though it is understandably upsetting to people who live there and don’t want any part in the project. Próspera is developing a bunch of possibly more significant things, too, like a commercial court, outside the national system, staffed with arbiters imported (perhaps via Zoom!) from Arizona. It still accepts Bitcoin as currency and it still says it wants to be like Singapore or Hong Kong to attract residents and businesses and commerce with its good rules and laws (spend enough time in this space and you’ll know how common, and indeed how ideological these statements really are.)

So Prospera is alive and well, free markets and all. But for how long? That is the $11 billion dollar question.

In 2022, Próspera’s Delaware-registered parent company filed an $10.7 billion lawsuit with the International Centre for Settlement of Investment Disputes (ICSID), a tribunal overseen by the World Bank, against the state of Honduras, accusing it of failing to respect international investment treaties.

These treaties, and the tribunals that settle their disputes, have always been controversial. The basic argument in favor of the treaties (of which there are hundreds) is that they help poor countries make money by appealing to outside investors who wouldn’t otherwise trust their domestic laws (the data suggest they don’t really move the needle, economically). Advocates think of them as an extra layer of security against, say, expropriation: what foreign entrepreneur would open a factory if they thought it could be taken away at a moment’s notice?

The argument against this system is that it puts investors’ financial interests before states’ by design, encroaching on national sovereignty and democracy and allowing shell corporations to sue entire countries for absurd sums of money.

That view seems to be gaining ground: in 2023, Elizabeth Warren and her allies criticized the Próspera lawsuit in a letter, and urged the U.S to support Honduras over the American plaintiffs “to ensure that such egregious cases can no longer disrupt democratic policymaking by working to eliminate ISDS liability in preexisting agreements in our hemisphere,” she wrote.

Then, in early 2024, Honduras went even bigger, announcing it would pull out of the ICSID convention altogether.

Importantly, this does not retroactively kill Prospera’s claim against Honduras. But it’s not a great sign for charter cities and the investors funding them, either: not in Honduras nor elsewhere.

And from where I’m sitting, the situation is pretty ironic.

Foreign businessmen lobbied a previous Honduran government to grant them a bespoke free-market jurisdiction with the rules and laws and regulations they liked best—a system they thought they could work with to spread their particular vision of a just society, and also, of course, make money. They pulled it off, but when the government challenged them, they went on the defensive and hired fancy lawyers at White & Case to sue the state.

Honduras kept fighting back. It moved to end the charter city concession, and made a global political statement by denouncing the rules that favor foreign investors in the first place. That means one less state onboard with the favorable-to-capitalists status quo. And not just that: it’s pitted American politicians, and international progressive groups against Próspera, when they might have otherwise ignored them.

So while we will be hearing from Próspera Honduras (or is it Próspera Delaware?) for many years to come, I’m starting to think that the Roatan saga is going to have repercussions beyond the confines of the little beachfront free zone. This result may well have been the plan all along: it’s certainly making a splash. But for the true believers, that might not end up being such a good thing.

Loyal readers: I'm sorry for the radio silence. It's been a hectic couple of years— a new baby, a move from New York to Ann Arbor and back, and smaller stuff like incessant daycare plagues and reporting trips to northern Michigan and the China-Lao border have kept me too busy to write regular updates.

I’ve also been putting the final touches on THE HIDDEN GLOBE, which now has a cover and a publication date of October 8, 2024. It’s the result of four years of writing, thinking and talking, and if you like Terra Nullius, you will LOVE the book. It has tons of new stories from weird jurisdictions from around the world (and beyond!), fresh insights into who built this world, and even some thoughts on what we can do to make it better.

The subtitle alludes to a major theme in the book—how money reshapes borders—but THE HIDDEN GLOBE is about so much more. There’s poetry, literature, and law; the world’s most interesting lawyer, consultant, and statesmen; and a 12,000 word elegy for a Soviet cruise ship. I can’t wait for you all to read it!

In the meantime, there’s one simple thing you can all do to help me out: pre-order the book. You can do it through Amazon, Bookshop, Barnes & Noble, Books a Million, Powells, Hudson Booksellers, Target and Walmart. If you order a copy from every single one, I will buy you dinner. You can also go down to your local bookstore and/or library and ask them to order copies.

Here are pre-order links for my fellow Canadians and for the UK, where it will be published in Feb 2025. The book will also be translated, but I’m still waiting on the details.

Pre-orders are one of the metrics that can really move the needle when it comes to book sales and promotion. And I really think this book could have a big audience, if we play our cards right. So please pre-order, and spread the word, and get in touch with me directly if you want to organize an event or have me speak at your school or workplace.

You might also consider getting an extra copy or two for friends, business associates, or family members.

THE HIDDEN GLOBE is for everyone but it is especially for:

• international wo/men of mystery

• uncles who love factoids

• Freakonomics fans and Freakonomics haters (!)

• unreconstructed dorm-room philosophers

• pirates, sailors and seasteaders

• employees of international organizations

• your friend who won’t stop talking about alien life

• libertarians

• anti-libertarians

• third culture kids (you know who you are!)

• people who pretended to read Thomas Piketty

Tomorrow, I’m off to another kind of weird jurisdiction*: Club Med. See you all on the other side.

* de facto, not de jure.

(Photo credit: Getty)

The latest political scandal out of the UK is too good/bad/mad to be true: Rishi Sunak, the Chancellor of the Exchequer, is married to a fiscal non-dom.

No, not that kind of dom—though she is, jurisdictionally speaking, pretty kinky. Non-doms are people who, all while maintaining a physical presence in the UK, are not considered domiciled there for certain legal purposes, and by extension, not taxed in Britain on their foreign income. They can be in two places at once, and have it both ways, in multiple countries. The jokes are so bad they write themselves!

What this means in practice, though, is that the conservative British politician in charge of his country’s tax policy is married to a woman who does not live in the UK for tax purposes—in spite of physically living in the UK with said British politician who rose to power largely thanks to Brexit, a movement known for its love of closed borders, patriotic slogans and chauvinistic nationalism.

How did this strange form of (non)-belonging come to exist? The legal scholar Kojo Koram points out that the origins of the loophole lie in the late 18th century, “when, to encourage imperialism, the government refused to tax wealth in the colonies unless it was brought to Britain”, ultimately helping the upper classes avoid tax on the wealth they’d accumulated in Empire’s peripheries. In more recent times, the status has been popular among oligarchs and billionaires and the ultrarich: squarely Akshata Murty’s milieu.

Sunak’s representatives have naturally tried to explain away Murty’s status, which allows her to avoid paying taxes on a presumably large chunk of worldwide income. They point out that as an Indian citizen, Murty cannot, by Indian law, hold two citizenships. By that reasoning, it supposedly follows that she can’t be legally domiciled in Britain, either.

The problem with this “disingenuous” explanation is that non-dom status is not conferred automatically when a foreigner moves to the U.K, but only granted after the applicant jumps through a bunch of hoops to demonstrate that they are somehow not fully “in” the country. Like most lucrative loopholes, it costs money (in this case, GBP 30,000 per year!) to remain a non-dom in good standing. You need paperwork, time, lawyers: not something that Polish plumbers or Punjabi shopkeepers can seek out or afford. But if you’re a certain kind of person, it’s worth it, because as a non-dom, you can benefit from even more loopholes in other jurisdictions still. The UK, where you definitely do not live, will in exchange, stay out of your offshore business.

To be perhaps exceedingly fair, many non-domiciled individuals probably do bounce around an awful lot—what else would account for their yacht, their six passports, and their Knightsbridge apartments that sit so empty for so long? But if you’re literally the wife of the guy who runs the Treasury for a conservative nationalist government, “bouncing around” is not a credible excuse. Even Trump appointee Steve Mnuchin couldn’t pull off this level of sleaze, and his wife was practically a modern-day Marie Antoinette.

Share

It’s too easy, though, to complain about politicians’ hypocrisy. So instead, I want to spend a moment on the deep, deep logic at the heart of the Rishi Sunak scandal. You see, for close to a decade now, Rishi Sunak has been one of the world’s greatest supporters of freeports, or places that, like his wife, are legally neither here nor there. Freeports, as I have written previously, are warehouses, industrial zones, and storage areas on a country’s physical territory, but outside its fiscal or regulatory boundaries. They are the deregulated industrial equivalent of the human non-dom.

Rishi’s love affair with freeports began when he was a young MP. In 2016, he published a white paper with a UK think tank entitled “The Freeports Opportunity”. In short, the report claimed that once Britain freed itself from the regulatory shackles of the European Union, it could establish customs-free, low-tax zones and in the process, create tens of thousands of jobs in economically distressed areas, because business loves a loophole.

Fast forward a few years: Sunak’s been appointed Chancellor, and though there’s been a lot of criticism of the purported benefits of freeports overall, the government has indeed opened a handful of them around the country. It remains to be seen what kind of an impact they will have, but Koram is once again a useful guide to understanding what informs these kinds of ideas. In his new book, Uncommon Wealth, Koram argues that policies that imperialists tested out abroad years ago are “boomeranging” back to the center, often with the effect of impoverishing ordinary people and serving billionaires and big business.

Freeports working around national regulations are one example of that; non-doms avoiding taxes are another. So let’s give ideological credit where it’s due: there is, alongside the glaring double standards, an admirable consistency with which Sunak conducts his personal and political affairs.

In response to Russia’s invasion of Ukraine, the European Parliament has reinvigorated its yearslong attempt to stop EU member states from selling their citizenship and residence rights to wealthy foreigners—this time, to Russians in particular. Their reasoning is that Russian oligarchs who help prop up Putin’s government could continue doing business as usual abroad behind the veil of another nationality, essentially using their second citizenship to avoid sanctions.

Whether they will be able to do this would depend on how financial institutions respond to the sanctions, and whether they treat their dual national clients “as” sanctioned Russians or “as” ordinary people with a different citizenship (particularly if the person is, say, Maltese and banking in Malta as a local, with all of a local’s rights). The Russians under sanction are named, and rather well-known people, so it seems hard to get around, but reports like the revelatory Suisse Secrets leak suggest that money is more important to some bankers than even war crimes, so there’s at least a precedent for being skeptical.

Also, while I am not a banking expert by any stretch, rich Russians (and non-Russians) have long established lots of ways to have access to their money wherever they go. They already have second and third citizenships. They have already diversified their assets by buying real estate and artworks and cars and boats; often, they’ve even moved their families abroad for good measure. Maybe they hold crypto! In other words, they have backup, and their backup has backup, which also has backup, which limits the effectiveness of certain sanctions in the first place. Does it suck to have your yacht seized during resort season? Sure. Is it annoying to get a call from your private banker telling you you can’t spend your own money? Definitely. But are these punishments the end of the world when you can camp out in Gstaad for the duration of the ski season, dine out using your daughter's credit card, and sell a Picasso or two for cash to a buddy? Cue the tiny violin.

There is nonetheless a clear symbolic and punitive aspect to the anti-second-passport move: everybody knows that a Russian passport is not a particularly great passport to have if you’re a member of the jet set and want to travel the world visa-free, so a superrich Russian is more likely to try to obtain a second or third citizenship than, say, a millionaire from France or Sweden. Again, it’s probably a good thing to make these peoples’ lives less comfortable, even in the abstract. I support it. I think we should pie them. The problem with the EU’s plan is that many of the people it wants to target already have secured second and third passports, through investments, or residence, or heritage, or a personal favor. To quote Jay-Z and Kanye: “I’ve got six passports/I’m never going to jail.”

Cutting off the chance to buy a passport in the EU won’t change things much for existing economic citizens. It also won’t prevent other countries that sell citizenship, like St. Kitts or Vanuatu or Antigua, from scooping up what’s left of the Russian market, and doing it real fast. (When I was reporting my book in St. Kitts, I by chance ended up renting a room in an Airbnb from a passport broker who helped Vkontakte founder Pavel Durov get his papers. I say “by chance” but it’s really not … that is just how common this sort of thing is!)

And it won’t cripple the industry behind the sale of citizenship, either. My hunch is that tons of wealthy and wealthy-ish people from states around and close to Russia will be looking to buy another citizenship because they’re so freaked out by what happened in Ukraine, and they want a plan B before it’s too late.

What about the countries doing the selling? The nature of these “citizenship by investment” programs (and their close cousin, residence by investment) is that they come and go and come again. For a while, in the early-to-mid 2010s, Cyprus was the go-to place for Russians; the country gained a reputation for doing everything short of stapling a passport to a millionaire's bank statement once they showed they'd invested more than EUR 2.2 million. Cyprus raised billions through the passport scheme, and subsequent leaks revealed that the majority of applicants between 2017 and 2019 came from China, Russia, and Ukraine. (Now’s a good time to remind you that Ukrainian oligarchs area also *a thing* and they are as hot for second citizenship as their Russian counterparts; my favorite passport anecdote is that when told that dual citizenship wasn’t legal under Ukrainian law, the politician Ihor Kolomoyskiy, who is Ukrainian and Cypriot and Israeli responded, “ah, but triple citizenship is not illegal.” I’m definitely stealing that line if I ever run for office.)

Anyway, Cyprus was apparently unwilling or unable to keep things clean. They even naturalized 1MDB’s Jho Low. You don’t need fancy due diligence software to figure out he’s up to no good, just Instagram! I imagine their laxity was the result of incompetence, laziness, bribery, and probably some cost-benefit math, but the result is that they ended up shutting down the scheme last year and are no longer in the business.

Still, to my knowledge, Cyprus did not rescind the majority of the passports it issued during the boom years. Why? Because revoking citizenship is really, really, really dicey. It’s literally what the Nazis did to Jews. It’s what Theresa May, in her capacity as Home Secretary, was reamed for wanting to do to ISIS members by the same good liberals who are now agitating for quite the same thing in the Russian context. It’s what Trump tried to do to, er,  Miami grandmothers? I am certainly not implying that Russian oligarchs are a persecuted class on par with German Jews and immigrants. They’re also not in the beheading business, as far as I can tell, and will not wind up stateless, either. What I’m getting at is that in all but the most extreme and morally unambiguous circumstances, revoking citizenship en masse is not a good look, whether it’s for political reasons or “naturalization fraud” (which, incidentally, is how McCarthyites sent anarchist Emma Goldman away to Russia). 

Revoking citizenship gets even more complicated when it’s obtained more “legitimately” (whatever that means) than by investing money, which happens too, and which the EU can’t stop. Roman Abramovich is apparently Sephardic enough for Portugal’s inquisition reparations passport. He is also Israeli, because of the country’s right of return law. Is it kosher to take those passports away, even though Abramovich is one of the biggest baddies in Putin’s orbit? Talk about a can of worms! So why should taking away any other passport without due process be OK? Given that a lot of people in the world, particularly those from the upper classes, have avenues of this sort available to them in some form, it’s pretty futile to tell them they can’t buy a Maltese passport anymore. Wealth finds a way.  

This is all to say that preventing Russian oligarchs from obtaining second or third passports is a largely ineffective way to hold them accountable or make them uncomfortable, and that it could have much broader and unwanted implications for the rest of us down the line. It won’t spell the end of citizenship-by-investment. It may even have the opposite effect.

I want to emphasize again that I think it’s a good thing to make the lives of Putin supporters harder, and I totally understand why European lawmakers would choose to pursue this avenue at this time. It’s politics, and the moment they’ve been waiting for. But take it from someone who’s spent way too much time thinking and reporting on and talking about passport-related politics: this is far too little, far too late.

When I found out Raymond Craib was writing a book on the history of libertarian exit strategies, I was super jealous—the highest form of flattery coming from a writer, given how petty we are. But now that I’ve read it, I am just so thrilled for all of us that he decided to take the project on.

Adventure Capitalism, which comes out in June (pre-order it here) is about men who tried to start countries in places where they thought no-one would get in their way (usually remote-to-them islands). It’s about the ideas behind their fantasies, and the political events and personalities that helped them flourish—and fail. If you’ve ever wondered about what came before the current wave of cryptocurrency entrepreneurs looking for a place in the world to call their very own, this book is for you, whether you are an aspiring seasteader, or you think these efforts are thinly-veiled imperial re-enactments in poor taste and moral judgment. So much contemporary writing about this intellectual space simultaneously lampoons and lionizes the Westerners who think they can simply declare themselves sovereign, and I get the impulse—I’ve certainly succumbed to it myself (let’s just say the protagonists … make it easy.) This book doesn’t, and that’s one of the reasons why I found it so essential: Craib is clearly very critical but he does not mock his subjects, opting instead to point out the weakness in their thinking in a historical, informed and methodical way.

There have also been a number of more whimsical and/or speculative published texts in this area of study that are broadly sympathetic to the exiteer’s cause—How to Start Your Own Country and The Sovereign Individual, to name a couple of cult favorites— but again, there’s been relatively little in the way of serious historical research into how exactly these attempts went, and in particular, the ideas and funds and groups that made them possible. There’s been even less attention paid to the the very real, non-fantasy places and communities that wound up being the targets of these experiments in DIY sovereignty, so it’s to Craib’s credit that Adventure Capitalism is as concerned about the real-life effects of these coups on ordinary people as it is on the masterminds behind them.

A final note: the book is really fun to read. It has a bit of everything: tragic/heroic individuals moved to act by their trauma, idealism, politics and eccentricity; high-powered economists influencing the political conversation at precisely the right moment; assorted grifters, mercenaries, spooks and crooks doing what they do best (or worst); Ernest Hemingway’s flunky brother. Craib teaches history at Cornell, so there’s some academic stuff in there for sure, but it comes with plenty of action to keep you entertained. If you read and enjoy Terra Nullius, I imagine you’d also be naturally interested in this book, so I leave you all with some thoughts from the author himself. I hope you enjoy the conversation!

Atossa Araxia Abrahamian: Your background is in Latin American history. How did you become interested in wacky secessionist exit fantasies? 

Raymond Craib: It was a combination of things that brought me to this project. Generally I am interested in the intersections of geography, history and politics and I try to explore those intersections however I can, regardless of the area-studies focus involved. So I tend not to limit my scholarly work to one country (my first book was on Mexico; my second, on Chile) and I like to think across geopolitical categories. This project in particular came a bit out of left field. My partner was raised in Hawaii and has been and remains an avid outrigger canoer (think of the canoes you see on the ocean in Hawaii Five-O). In Ithaca we have a fabulous lake—Lake Cayuga—that is 38 miles in length and some 400 feet deep in some areas so it can often feel like being on the ocean with very active currents, wind and waves and the like. So we both did outrigger on the lake every summer (she’s hard-core and paddles year-round; I don’t) and one summer we ran, with a couple of other paddlers in the outrigger club, a class for teen camp counselors, teaching them how to outrigger. We would paddle out to the middle of the lake, pause to jump in for a few minutes and then I would talk for 10 or 15 minutes about the history of outrigger, of open ocean navigation, and Oceania more broadly.

In the process of doing bits of research for that summer I came across seasteading—the Peter Thiel-backed and Patri Friedman-led effort to build libertarian colonies on the high seas—and was struck by the guiding assumption that the ocean was unclaimed and open for colonization, particularly in the context of a long history of Oceanian navigation, usufruct, migration, and the like. And of course the allusion to home-steading just drove home the settler colonial underpinnings even further and at the same time suggested a much longer history to such projects.

That became the starting point for looking more closely at libertarian ideas of territorial exit and private sovereignty. It soon became obvious that there is a very long pedigree to such ideas and I decided to not put the seasteaders front-and-center but to instead examine how they were the latest manifestation of long history of private colonization schemes and efforts to rework the idea of sovereignty (in part because I am interested in that kind of longer view and in part because the Silicon Valley tech culture seems convinced that its projects and schemes are new, innovative and sui generis… and they are not.)

AAA: When you began your research, what were you expecting to discover, and how did the result surprise you?

RC: Honestly I wasn’t quite sure what to expect although I knew going in to it that I wanted to get at the texture, the detail, of what happened in the places exiters targeted. I tend to be a historian who gets obsessed with the nitty-gritty of what is happening ‘on the ground’ and I knew at some level that the story of exit was to be found there, rather than in grand pronouncements, aspirational statements, investment prospectuses and so forth. So I did a lot of archival work—in the collections of journalist Andrew St. George (held at Yale); of British Special Branch officer Gordon Haines (held at the National Archives of Vanuatu); in the National Archives in London; and in materials gathered on Oliver and some of his partners through Freedom of Information Act requests to the FBI, among others.  I am not a historian of the US so I think some of the things that surprised me—the intensity and depth of the libertarian eruption of the 1960s, for example—would not surprise a historian of the 20th century US. Perhaps I should not be surprised, but I did find striking how deaf to history current exit projects seem to be. The seasteaders, who style themselves as innovative thinkers about sovereignty and rethinking governance, promote and embrace some of the most maudlin and saccharine tales of western expansion and pioneer romance. They sound at times like traditionalist, die-hard right-wing patriots. But of course it should not be surprising because they still have not found a way to square the libertarian peg that fetishizes property rights with the historical circle of violent expropriation. So they fall back on picture-book narratives of empty lands and utopian freedom-lovers. The use of -steading in their own name tells you what you need to know. I’ve written someplace else that they should read less Lynne Cheney and more Cormac McCarthy.  

AAA: You spend quite a bit of time in the book talking about Michael Oliver, the Las Vegas real estate mogul behind the would-be Republic of Minerva, a tax-free, regulation-free micronation that was to be built in the 1970s on reclaimed land in Tongan territorial waters. In many ways he’s a very ideological, very extreme libertarian. Yet he comes off as a pretty complex character psychologically. Who is he, and was there anything about his life or his biography that helped you get in his head?

RC: Yes, Oliver is a central figure in the book and someone who I found very compelling and who I wanted to try to make sense of. My answer here will be a bit lengthy because there are a number of important points worth making. To begin with, at some level he was a natural choice as his projects in the 1970s are notorious in exit circles and historiography. His 1968 self-published book (A New Constitution for a New Country) was a major success and went through multiple editions quite quickly. He also was not shy about giving interviews and being fairly public about his efforts. But as I researched further a couple of things struck me. 

For one, there was a frustrating tendency in the writing on Oliver’s projects to see them as sort of comedic and absurd, what I refer to as the narrative trope of “crazy, rich Caucasians.” (The rare exception here is the work of Anthony van Fossen on sovereignty and tax havenry in the southwest Pacific who wrote very carefully about Oliver and his projects.)  There is a patronizing and dismissive tone in much of the work and I wanted to avoid that by taking his projects—and him—seriously and by situating them meaningfully in the context of the era. Oliver’s story is a compelling one: Jewish, from Kaunas, Lithuania, he was the only member of his immediate family to survive the Holocaust and was 17 or 18 when rescued by US troops outside of the Dachau concentration camp. He then emigrated to the US and made a home for himself in Nevada. His experiences made him understandably hyper-attentive to his political surroundings and he worried about the threat of totalitarianism which, like many US liberals and conservatives alike, he associated with communism as much as with fascism. This resulted in a convergence between libertarianism and social conservatism that may strike readers as strange, even contradictory, but is central to how we should understand US libertarianism (and I say US libertarianism because for most of the world libertarian is synonymous with anarchist—that is, as both anti-state and anti-capitalist—whereas in the US libertarianism is devoutly capitalist and agnostically anti-statist.) It is also a convergence that resonates with the positions taken by some of the more prominent libertarian or neo-liberal intellectuals of the 20th century who shared similar experiences or concerns: Hayek, von Mises, Friedman, Rand, Rothbard, among others. 

Share

The second thing that struck me in researching Oliver’s projects and that led me to devote substantial attention to them is the lack of attention given to the social and political histories of the places where he sought to establish his new country. The fact that libertarian escapists found little success in places such as Pacific seamounts and decolonizing archipelagoes such as the Bahamas and the New Hebrides resulted from many factors, including the larger structural and geopolitical dynamics within which they operated as well as their own ignorance and arrogance regarding the places in which they landed. But it also resulted from the complexities they encountered on the ground. Many people living in these communities had had enough and were not ready to trade one colonial master for another; they were not ignorant of the potential consequences of libertarian escape projects; they had their own understandings of property, territory, the ocean, and the land that did not dovetail with that of these new arrivals; and they had their own understanding of freedom that did not match that of the libertarians. At the same time, exiters found allies in these places too. Some residents and leaders supported exit projects, seeing in them opportunities to use foreign investors and speculators to their own ends, whether it be to steer their own political destinies, to stave off more radical change, to make money, to sustain racial domination (in the Bahamas, for example), or because of shared ideological perspectives. In any case, I wanted to delve deeply into the social histories of these places to show how and why exit projects were rarely, if ever, simply imposed from outside and onto a uniformly intransigent population.

And thirdly I found that in much of the writing on these projects Oliver is not just the central protagonist, but the only protagonist. In the process, the collective of wealthy individuals who invested in and promoted such projects is elided: men such as wheat and housing magnate Willard Garvey; financier and philanthropist John Templeton; horologist and yachtsman Seth Atwood; international investment specialist Harry Schulz; and University of Southern California philosophy professor John Hospers, among others. The monies and connections such men could deploy in support of their endeavors hints at a much more robust world of libertarian exit, one that cannot simply be dismissed as the utopian dream of one or two marginal cranks but rather must be understood as a long-term structural possibility for the ultra-wealthy.

This brings me to a final point regarding Oliver and your question about psychology. I spoke with Oliver a couple of times on the phone. For most of the time I was doing my research I was not even sure he was still alive (he was born in 1928). It comes through in the published interviews he did with Reason and other outlets at the time and he also reiterated this to me: he was not a utopian (he did not believe, for example, that his new country would be an idyllic paradise free of conflict) nor did he pursue exit projects as a means to hide his wealth or avoid taxes. The operating premise for Oliver was to carry out what he called a “moral experiment” by designing a new country run through contractual, capitalist relations that, in theory, would provide the maximum possibility of individual freedom and, I argue, would provide (in theory) a means of self-protection from the dangers of demagoguery, mass politics, and the like. This does not mean of course that the profit motive was not also important. The benefits of tax havens and offshore financial centers, for example, figured directly in the libertarian exit calculus but the broader point is that for libertarian exiters there is no contradiction between the moral and the entrepreneurial. The profit motive is the moral experiment; the individual at play in the market is the sine qua non of freedom. Exit is thus not solely a means by which libertarians can implement their ideas; it is a fundamental part of the idea itself—a right to opt out of and opt into societies with the ease of a wealthy consumer.

Subscribe now

The commitment to a “moral experiment” helps explain why such projects are repeatedly pursued with such vigor despite the costs and the headaches involved. After all, if the idea was to avoid paying taxes or to make more money, most of the individuals involved in such schemes had the necessary resources to employ a team of tax consultants and attorneys and numerous offshore financial centers and tax havens beckoned. There was little need to design elaborate escape plans. Similarly, circumventing the regulatory state could be achieved without undertaking radical territorializing projects. 

A last point I should make here is this:  the more recent exit strategists (the seasteaders, the free private cities advocates, and the Start-Up Societies promoters) share some things in common with Oliver, not least of all an adoration of Ayn Rand. But the differences are also worth noting. For one, they came of age in an era defined by Reagan and Thatcher and thus their anti-statism strikes me as abstract and generic (absolutist, perhaps) rather than specific to an idea of totalitarianism. Second, and perhaps as a result of the first point, they hew more closely than Oliver did to the more Nietzschean aspects of Rand. What I mean by this is that their projects are not driven by a fear of the masses and totalitarianism—they seem indifferent to the general public and express disdain for democratic politics—but by an urge, a will, to bend reality to their design. They seek not to escape the state but to recast it in their own image. 

AAA: Can you sketch out an “ideal type” of a libertarian exiteer who seeks to start his own country? 

RC: I’m not sure but I can try. To begin with I should briefly define what I mean by libertarian. As I mentioned previously, I use the term as it applies to US libertarians and who, for the sake of clarity, we might call market-libertarians (I avoid the term anarcho-capitalist). Many of the individuals I yoke under this term would not necessarily have referred to themselves as libertarians at the time but they still did share certain traits, such as the following:  a disdain for the welfare and regulatory state (not the state per se); a radical commitment to free enterprise; a fetishization of the rugged individualist and unencumbered entrepreneur; a fear of the masses; a worldview that conflates communism, socialism and fascism; and an ontology that equates individual private property rights with freedom. 

Defining ‘libertarian’ helps us understand ‘exit’ better because the hyper-capitalist orientation of the people I study sets them apart from other kinds of exit societies that one might find in the historical record: maroon communities forged by runaway slaves; acephalous highland communities composed of peoples fleeing state conscription and enslavement; semi-sedentary peoples who sought to remain one step ahead of encroaching states and settlers; revolutionaries who roamed the late-eighteenth and early-nineteenth century Atlantic and Caribbean seeking to create multinational and multiethnic countries of their own; or autonomous territories such as those founded by the Zapatistas in Chiapas, Mexico. All of these might be considered experiments in territorial exit but they share little in common, ideologically and structurally, with those of Michael Oliver, of seasteaders, and of the advocates of free private cities.

My point is that form should not be privileged over content. Any analysis of exit needs to understand what it is people are striving to leave but also what they are striving to build. A maroon community of former slaves who escaped plantation exploitation bore little in common with, say, an ecovillage built around the logics of green capitalism. Exile communities that grew from collective efforts to mitigate capitalist exploitation and labor subjugation and that grew organically from the ground up are not comparable to escape plans that privilege property acquisition and individual sovereignty and tend to be preplanned and engineered from above. They bear distinct, and largely incommensurable, understandings of what constitutes freedom and of what constitutes oppression. I am not sure if that helps ‘positively’ define an ‘ideal type’ but hopefully it does provide a useful distinction when thinking about exit, exile, and evasion and the class politics that are invariably a part of the equation.

AAA: How seriously—from a political standpoint, and a practical one—ought we take people who want to start their own countries, or set up autonomous free zones in poor countries? 

RC: This is a difficult question in that, at one level, there is a risk in giving exiters perhaps more credit than they deserve. Certainly, some of the more recent exit projects resemble nothing more than a Fyre Festival grift. After six years or so of research on some of these projects I was repeatedly struck by just how unprepared exiteers were for the response to their projects—whether in the southwest Pacific, Tahiti, or Honduras—and how naïve they seemed and how little historical understanding they had of the places they targeted. It is a lethal combination of ignorance, arrogance, and money. On the other hand, ignorance and arrogance are no guarantees, given the amounts of money involved, that these projects won’t succeed in some form (and part of the question here is what constitutes success). Of particular concern is the kind of process that unfolded over the previous decade in Honduras in which tech bros keen on exit and US social conservatives who had close links to the Reagan administration and right-wing establishment found willing partners for their exit schemes in the illegal regime that controlled the country after a coup d’etat in 2009. Such schemes can also count on the support of networks of wealthy, libertarian think tanks such as the Atlas Foundation.

I worry that these kinds of collaborations will become more common in the future given the pressures of climate change, the dramatic and growing disparities in wealth, and the on-going assault on governance structures that include the public good. One of the authors (Gabriel Kuhn) who kindly wrote a blurb for my book captured this question with particular eloquence: “free-market secessionists and gung-ho libertarians are only the most extreme expressions of neoliberal hegemony.” So, yes, I do think we need to take them very seriously.

AAA: How did the US libertarian “establishment” (to the extent that it existed) react to these types of projects?

RC: I think it is fair to say the response was and remains mixed. One of the things I sought to highlight in the early chapters of the book is the range of libertarian thought—or market-libertarian thought—that emerged in the US in the 1960s. (Brian Doherty’s Radicals for Capitalism is a useful book—by a movement insider—in tracing this history.) I am not sure what would have constituted the libertarian establishment of that era but whatever it may have been, the exiters were on the fringes of it to some degree, but not perhaps as marginal as one might think. I try in the first chapter in particular to show just how much the idea of exit or escape permeated popular culture writ large in the 1960s and 1970s, as a result of fears regarding demographic, ecological, and/or monetary collapse. Exit projects of various kinds were not at all uncommon, even if rarely successful, and this makes sense as it was not a huge step to imagine a commune on the ocean, rather than in northern California; or a gated island in the Caribbean rather than in suburban Los Angeles. The difference of course was the desire to exit, rather than be an expatriate, and to set up a government run entirely through private contract.

Having said that, it is also quite clear than many libertarians had little patience for exit projects. Murray Rothbard—who himself raised libertarian hackles by allying himself at times with the New Left—was an outspoken critic of exit projects because he thought exiters would do better to put their money and time into changing things ‘at home’ rather than making a new country. Nor was Ayn Rand a fan, despite her Galt’s Gulch (an Atlantis in the Rockies) serving as a model for many exiters, both in the past and today (interested readers should look up Galt’s Gulch Chile for an especially revealing and dreadful exit scheme that recently imploded.)

AAA: You write that many of these projects that purport to do something radical and new don’t challenge the nation-state system much at all. Why is that?  

RC: I made a decision early on in researching this book to stick to projects that were explicitly territorial. So, for example, I do not address exit via the creation of internet or digital communities or some of the trans-humanist projects (conversion of human consciousness into computer code, for example). Those seem to me both fantastical and radical. The territorial projects do not. Perhaps by default—by being territorial—they are not but I think it is also by design. That is to say, the promoters of these projects themselves are always hedging their bets. For example, leaders in the seasteading movement ask why individuals should be restricted from exiting if they wish to do so. “People should be allowed to opt out of governments they didn’t choose. . . . Seastead pioneers don’t need you to vote for them. They only need you to not petition your politicians to stop them.” But I find this to be a strange plea. There are currently no laws prohibiting them from opting out, of exiting, of renouncing their citizenship. They have that choice. They have chosen not to make it. They might argue that such a choice is not a choice at all, given that it would leave them vulnerable and unprotected unless they had a state within which to opt in. Welcome to the reality for most of the world’s population which is subject to the unequal laws and coercive forces of both the state and the market and which lacks even the most minimal of the financial and political resources necessary for exit and entrance. 

The fact is the promotional literature that extols free-market states, private cities, and crypto-utopias often reads less like innovation in governance and more like euphemistic cover for fairly rudimentary and age-old practices—land and water-grabbing and real-estate speculation—albeit wrapped in the language of disruption and decentralization. (The history of exit I explore in my book only affirms such a suspicion.) This is Glengarry Glen Ross for the tech era. Our own private meta-curse. 

Exiters themselves are willing to admit that exit is less a rejection of the state than it is a form of arbitrage. I would go further and argue that exit is less an argument for “no state” than it is an argument for the further privatization of the state; it is less a rational experiment in governance than it is an indulgent theology of the self. The result of new forms of territorial exit will not be an opt-in borderless world of entrepreneurial abundance but a world of hardened borders, privileged excess, and collective scarcity; a world pockmarked, as novelist and political theorist China Miéville observes, with private territories “as ferociously exclusive as those of any other state, and more than most.” So what is at stake is not exit from the nation-state but an on-going reworking of the state at the hands of, and in favor of, the most privileged. In the end the projects are more J.W. Marriott than Thomas More. Less utopia than time-share sovereignty. 

Yesterday, the American venture capitalist Tim Draper became the first digital resident of Palau, a small nation in the Pacific ocean due east of the Philippines and north of Indonesia. The event was marked by a ceremony conducted over Zoom, with four Palauan officials, including the new president Surangel Whipps Jr, sitting masked up in a room as Draper joined in from an office in California.

The event had all the features you’d expect of an official state function: participants stood up for the national anthem, flew the national flag (it’s really cool!), and waxed philosophical on the country’s traditions and history. Did you know that the islands are the birthplace of the OG blockchain some 4000 years ago? Apparently, islanders would harvest and transport gigantic stones and mark their ownership through trust networks and oral tradition. I certainly grasp the “block” part… but not so sure about the chain. Fortunately for you, that is not what I’m here to write about!

Palau’s new digital residency program essentially provides people with a sovereign-backed digital ID with which they can do things that their home jurisdictions might not (yet) allow. In other words, it functions as a flag of convenience for people doing things online. I had the privilege of interviewing the president of Palau, Surangel Whipps Jr., about the project, and he’s definitely the chillest head of state I’ve ever spoken to: he had a Hawaiian-style shirt on, a cool floppy haircut, and seemed like he’d be really fun to have a longer chat with because he uses real English words, not corporate management speak.

During the interview, I asked him to describe to me someone who could benefit from being a digital Palauan, and he explained that residents of states like Hawaii can’t buy and sell cryptocurrencies from Hawaii with their Hawaiian ID (note: they could, but my understanding is that it’s a pain in the ass because of the way the exchanges are restricted.) With a digital ID, the idea is they’d be able to participate in these markets more freely and essentially transcend their location and nationality … with an assist from Palau. And yes, there will be background checks similar to the ones banks use to make sure they aren’t doing business with money-launderers (who all still seem to have bank accounts, but OK.)

For individuals, this is a nice service to have; for Palau, it’s the first move in a bigger bid to become a place with the kinds of regulations that draw crypto-currency companies to register there, thereby making the country money through fees, licenses, taxes and whatnot.

Palau is not the first country to go here: Estonia has a relatively longstanding and popular digital pass that gives foreigners access to its banking and corporate infrastructure (as it happens, Tim Draper was the third E-stonian) and other jurisdictions, including NEOM in Saudi Arabia, are making their own plans (Draper said at the press conference he’d been in conversations with some people in Kazakhstan, “but I think there’s been turnover there so I think they dropped it.”)

Draper also gave a spiel on the importance of economic freedom, digital innovation, and the usual crypto-boostery Silicon Valley fare. I’m not going to get into that either because I’m sure you’ve heard that stuff before—and also because there was a more interesting (to me) discussion about the role of individual states in creating this new digital world, and the kinds of states that tend to get involved in these forward-thinking projects.

In our brief interview, Pres. Whipps was totally clear-eyed about how Palau’s national sovereignty was not a magical mystical potion, but an asset that can help the country make money. Draper, on his part, pointed out that the combo of state sovereignty + smallness can often yield interesting results from a regulatory standpoint. “I’'ve noted the innovations are now coming from smaller countries: Macau got very excited about Bitcoin, Switzerland also got very interested in Blockchain, recently El Salvador made Bitcoin a national currency and these innovations are happening in small companies, er countries,” said Draper (catch the Freudian slip?) “And I thought about how venture capitalism is, and [how we] invest in entrepreneurs that start with very small businesses… that impact big industries.”

I’ve been thinking a lot about smallness lately as well—partly because I recently read Christopher Bruner’s 2016 book about offshore centers. I’m of two minds about the book: one one hand, it argues rightly that “offshore” is about so much more than low tax, and that laws, regulations and loopholes can actually be way more appealing to companies registering in exotic locations than low or no taxes (though those never hurt!) Palau, if successful, will be a good example of that.

Bruner doesn’t necessarily believe this system creates a “race to the bottom” from a legal or regulatory standpoint, though, because these places tend to be quite well governed/not super corrupt. I guess that really depends on your definition of corruption (so much reprehensible stuff (like state capture) is totally legal!) and also how much you factor in global problems like inequality and the role of offshore centers in all that.

Politics aside, Bruner sketches a clever profile of an archetypal “market-dominant small jurisdiction”, which I’ve copied below. I thought it was a useful schema, particularly when it comes to some of these wannabe crypto centers. It’s a bit wonky but it’s easy to see where Palau/digital residency fits in.

While working on my long-suffering second book, I’ve thought a lot about the concept of deterritorialization, and whether it’s actually happening. The idea that we can actually do away with the physical world and transact and interact purely online is really silly to me—have we learned nothing from the drudgery of pandemic Zoom? It sucks! No-one likes it! This also holds for the potential of digital communities/countries—the whole reason people want to start ridiculous Crypto Islands or whatnot is because we’re social creatures and being online gets old and boring and has limits. What’s more, our geopolitics will not allow a sovereign entity to be conjured up out of the Metaverse, or an asteroid (though I’m not ruling it out in the future). If you want that kind of power today, you have to work with what the world already has: a couple hundred countries, the landmass they occupy, and the people and politics in them.

It’s also true that so much stuff, and particularly stuff that holds value, isn’t really a thing anymore so much as a contractual relationship “coded” in national law, as the brilliant Katarina Pistor puts it, before it is de-nationalized and de-territorialized and, I don’t know, sublimated, I guess. Countries—and the gaps between them—are what enables capital to become stateless. And that’s the rub: you have to have a solid place in order to make things this slippery and placeless. Tax havens have done this for a long time for money, and digital residency programs are an attempt to do it for people (and, of course their money.) Which, when you think about it, is pretty cool, but will definitely not help solve physical human things like climate migration.

That said, there’s apparently a 300,000 person waiting list to become a digital Palauan, and you can be sure that I am on it (though probably, sadly, near the bottom.) If I am successful, I will post about it some more!

The wonderful thing about not charging for this newsletter is that I am accountable to no-one, which means I can go silent for six months without developing a guilty conscience. You could say that like many of the things I write about, our relationship, dear subscribers, is duty-free: we owe each other nothing.

That said: if you enjoy what you read, or want to talk about it, please share the post with a friend or send me an email. There is only one of me on the Internet, and I promise that I’m very easy to track down.

Share

The reason for my re-materialization today is that there’s a new space station in the works… and I have questions. This is a Jeff Bezos production: his rocket company Blue Origin announced it would be teaming up with some other private space firms to create a (physical!) platform with as much habitable space and technological capacity as the International Space Station.

Private enterprise in space is nothing new, but this might be the first step towards something much bigger. Bezos has talked for years about how he expects dirty, heavy industries that “stress Earth” to move into space, along with the millions of workers working in these industries who presumably also “stress Earth” by merely existing (or at least, “stress Jeff Bezos” by expecting to get paid.)

This vision of the future is not uncommon in space/tech circles. And, if you leave humans out of the story and try not to worry too much about the ethics of polluting dark matter, I suppose it has its merits: I, too, would love to not confront yucky industrial areas the moment I leave New York City, and yearn for the oceans not to be gunked up with toxic waste so my kid can someday swim in them.

But my questions about extraterrestrial industrialization today are less ethical than well, spatial (sorry). For the past couple of months, I’ve been working on a book chapter about export processing zones—special places in one country where goods are manufactured for export to other countries. The zones typically wind up being in poor states with cheap labor, like Bangladesh; the goods made inside them get shipped off to be sold in wealthier parts of the world, like Europe.

A perk in these zones, which I’ve mentioned a couple of times in this newsletter, is that the companies in them often operate largely tax-free under a separate set of rules from the rest of the country. Between the elimination of customs duties or tariffs on the yarn, rubber, steel or other materials brought into the special zone for workers to make things out of; deals with the receiving countries to levy little to no duties on the manufactured goods themselves; and other financial or regulatory breaks to sweeten the deal, the firms doing the offshoring can save a bunch of money.

Subscribe now

You’ve heard versions of this story before, I’m sure. These zones are now ubiquitous, nearly to the point of banality—my pals at the Adrianople group just launched a very cool new map visualizing their reach. But in their early days, export processing zones were the midcentury businessman’s version of sending heavy industry to space. These bosses did not care terribly much about how laborers they would never see would be treated at the margins of a country they would never know. They did not want their dirty business to “stress America” when they could “stress” Puerto Rico, Taiwan, or India. They could get the work done for cheap, and to top it off, convince themselves of the altruism of the arrangement: they were creating jobs! In poor countries!! For women!!! Saving the world!!!!

This isn’t to imply that every special economic zone is necessarily a smoldering hellhole; some are, but most aren’t. Still, to me, there’s a straight line between Nike’s “garment worker in Bangladesh” and Bezos’ “forklift operator on Mars.” The difference is timing and technology.

In light of these parallels, I have lots of questions and very few answers. (Please comment if you have answers.)

- Assuming the cryogenically frozen brain of Jeff Bezos pulls off his masterplan two hundred years from now, will the fruits of his employees’ space labor—the flying cars and gadgets and clothing produced in what is still no man’s land—be considered imports, or … something else? (Astronauts returning to Earth with space trash already had to clear customs, but that was to exit Kazakhstan, not re-enter the atmosphere or national airspace.)

- Will duties be determined by the country these space-goods wind up being sold in, the Earth-based registration of the space-based subsidiary, or the citizenship of its expatriate workers? (Is expatriate the right word?)

- Will the World Trade Organization get involved? (Will it change its name?)

- Will the Extraterrestrial Processing Zone (h/t Quinn!) be an anarcho-capitalist haven, or will the space station authority impose “land” or “use” taxes?

- I guess what I really want to know is: what duties do we have in space?

A rendering of blockchain city (via NYTimes)

You’ve probably heard a friend, colleague or relative repeat the cliché that the world would be a much better and more efficient place if governments were run like companies. American businessmen love this line; so do American politicians. Gov. Steve Sisolak of Nevada apparently loves it so much that he’s proposed legislation letting companies become actual local governments—not the old-fashioned way, by sending lobbyists to wheedle their way to greater influence, but by giving select companies physical pieces of land over which they will have the right to exert the same power as any other Nevada county. That includes the authority to immediately or eventually:

• Charge taxes (or not!)

• Create school boards (or not!)

• Run courts of justice (or not!)

• Hire a police force (or not!)

• Provide municipal services like trash pickup (or not!)

The thing to remember is that whatever gets built, it’ll still be in Nevada. And Nevada? Still in the U.S. Sorry to break it to you, but seasteading, this ain’t.

Share Terra Nullius

It’s more helpful to think of Nevada’s proposal as the logical progression of Trump’s “Opportunity Zones”—geographic carveouts with big incentives for developers, ostensibly to help poor communities. Opportunity Zones have been broadly panned as not very helpful for the people living in and around them. They were, however, good for Trump’s friends.

You can also think of Sisolak’s idea as a spin on an old American tradition: the company town, where a firm is service provider, employer, landlord, and schoolteacher rolled into one. I was surprised to learn that at one point, three in one hundred American residents lived in a company town. That seems unlikely to happen again given that today’s most prominent firms—Uber, Lyft and Amazon—are going out of their way to avoid giving many of their employees benefits.

Nevada is a natural place for this kind of jurisdiction to emerge. Not only has it put itself on the map with various forms of regulatory arbitrage—adopting a more permissive approach to governing gambling, marriage, sex work, taxes, and so on— it’s also home to 32 tribal reservations and colonies, which enjoy tribal sovereignty. This is not to draw a direct line or ignore the vast historical, political and cultural differences between a reservation and a drive-through chapel. All I mean to say is that Nevada is delightfully replete with weird jurisdictions, so it’s not that surprising that its Democratic governor would be amenable to such experiments.

Nevada also has quite a bit of space, which is important should this legislation come to pass. The way it would work is that businesses that hold deeds to more than 50,000 acres of land not inside an existing district would be allowed to essentially set their own rules, as long as they had $250 million in the bank and pledged to invest a billion dollars more in the next decade.

Oh, and there’s one more requirement: Nevadan local self-government is “limited to companies working in specific business areas including blockchain, autonomous technology, the Internet of Things, robotics, artificial intelligence, wireless, biometrics and renewable resource technology.”

This all sounds highly specific, right? Like, how many huge, well-capitalized, land-holding blockchain companies are there?

Share

At least one! It’s called Blockchains L.L.C, and it’s been totally open about its intentions to achieve exactly this level of autonomy for years. Its owner, Jeffrey Berns, donated $50,000 to Sisolak’s campaign, and has gone public with his stated goal of creating “a sort of experimental community spread over about a hundred square miles, where houses, schools, commercial districts and production studios will be built,” per the New York Times.

Or, as Berns puts it: a “sandbox” that will “impact humankind for the better” with “as many possibilities as there are grains of sand in all the sandboxes on earth.”

Blockchains LLC is your average blockchain crypto-something-something change-the-world-BUY-MY-COINS-revolution, which is to say, it is both wildly ambitious and utterly incomprehensible to a normal person. If you have the patience, you can watch this video of Berns talking to a hologram of a 12-year-old girl about his vision. It’s pretty weird.

If you cut through the crypto-bullshit, and I warn you, there is a lot of it, there’s the nucleus of a legitimately important mission: how to create a meaningful and secure link between our physical selves and our digital ones. That, I think, partly explains the seemingly paradoxical desire to have a blockchain-based county in the Nevada wilderness.

As far as I can tell, Berns’ company is in the business of self-sovereign identity: creating tools to give you and me the power to show that we are in fact who we say we are. If you’ve ever had trouble getting a driver’s license, tried to fix a typo on your social security card, had your identity stolen, failed at un-muddling your tax returns, or attempted to restore a dormant eBay account, you will know that this is much, much harder than it sounds. Our digital trails and shadows simply do not correspond in a meaningful way to our arms and legs and brains (and souls, if you believe in that sort of thing.)

Blockchains LLC is one of many tech firms trying to give individuals control over these scattered parts. The goal is to match each person with all their “bits” in a secure way without state intervention, and the blockchain is a medium through which to do it. Berns has apparently also bought vaults in the mountains of Sweden and Switzerland where people (well, his clients) can store “private keys” storing proof of their identity.

Notice that the key, the bunker, and the mountain are unique, physical things—portals to all the other stuff, which is digital and less tangible.

The longing to start a physical city, country, or community from scratch seems pretty fundamental to the way humans operate on a political and social level. Lately, I think the sheer force of this desire among tech people says a lot about how societies haven’t figured out how to simultaneously exist both on earth and online in a reasonable way. The same tension is lurking beneath debates over whether Trump should be banned from Twitter: we agree that what happens on a tech platform kind of corresponds to things that occur in the material world, but it’s not a one-to-one match, so we’re not sure what to make of this watery space in between, especially given the non-territoriality of where these contentious speech acts are happening.

In addition to fulfilling one rich guy’s massive ambitions, a blockchain city, can therefore also be understood as an effort at consolidation: an attempt to reconcile two parts of our lives that currently operate on different planes.

This almost goes without saying, but I also think we are living through a time of deep human frustration over a lack of new frontiers, and that people who pride themselves on disrupting things and thinking big are offended by the fact that they can’t just go and colonize a new place like their predecessors did. Not to make everything about asteroid mining… but this is definitely related to asteroid mining.

If I were a gambling woman I’d wager that the Nevada legislation doesn’t pass: the proposed legislation requires public hearings, and I can imagine a big grassroots effort to prevent it from going through. Even the Charter Cities Institute, a think tank whose goal is to bring about exactly this kind of legislation, cautions out that the public hearing “‍invites trouble in the same way that discretionary review, etc invites trouble from NIMBYs with respect to new housing development, but is probably an unavoidable inclusion.”

I can nevertheless see the state giving enough concessions to Berns and his firm for this legislation not to matter. Nevada wants Berns to stay, and with so many other states courting zillionaires like him, the zillionaire has all the leverage. His company will end up with a measure of political and administrative control over its land, and hand off the more annoying stuff to the state or another county. I think (hope?) serious people who get excited about tech stuff ultimately want to focus on the tech, and not spend their time figuring out how to put, I dunno, waste management on the blockchain.

Thinking about how best to build and organize a new city, country or community is obviously a fun idea. It’s also a really important practice—ever since Plato’s Republic, it has defined political philosophy. But in practice it’s also a huge pain in the ass. Why? Because it’s not so easy to run run a government like a company.

Late last year, NASA announced that it would be partnering with four private companies to collect what amounts to a few handfuls of soil from the moon. The contractors have to carry out their mission by 2024, at which point NASA may or may not pick up the samples and bring them back to Earth. What they will do with them is TBD.

Like a lot of space-related news, the headline is more exciting than the reality. Moondust sounds romantic, but I’m guessing it looks a lot like the crud that’s been accumulating behind my couch for the past six months. The amount of soil NASA’s asking for is a quantity that might have been caught in Buzz Aldrin’s shoe, if gravity had played a role. And the harvesting will be carried out by robots, not astronauts. Perhaps that’s why the companies were awarded for between $1 (that’s -one-) and $15,000 to do the job. A lunar gold rush, this is not. But for how long?

Back in September, after NASA announced its request for proposals, administrator Jim Bridenstine gave a press conference to explain the agency’s motives. 

"Right now, we're trying to prove the concept that resources can be extracted, and they can be traded," said Bridenstine. "And not just traded among companies or private individuals, but also among countries and across borders — private individuals in other countries."

So it’s not about the dust, really. It’s about the principle of the thing: who gets to claim it, who gets to trade it, who gets to speculate on its future value, and so on and so forth. On earth, we have entire Bloomberg terminals accounting for this stuff in real time. But on the moon, we’re back to square one.

And that’s where it gets weird. The moon is not part of planet Earth. The moon is not encased (to borrow Quinn Slobodian’s term) by what we think of as state lines or national borders. The moon does not shine exclusively on the United States of America, as much as some Americans might think it does. And international treaties since the 1960s have stipulated that much like the high seas, no country can plant its flag on a celestial body and declare itself its sovereign. 

The US isn’t going that far. But in practice, America (and a growing number of other countries) is doing something like it. And there’s a convincing argument that claiming property is practically more significant than declaring an abstract notion of extra-terrestrial sovereignty.

Terra Nullius: On Legal Fictions

Political philosophers have been arguing about what justifies private property for centuries. John Locke believed that property was a natural right, and therefore not fundamentally contingent on the rules of any particular nation, empire or other jurisdiction. For Locke, “mixing” labor with resources justifies ownership: If I were to find an unclaimed piece of land, fence it in, and cultivate the soil to grow apples and pears, the land, the apples and the pears would rightly belong to me, so long as I wasn’t causing others some terrible privation*. The role of government, per the theory, is to recognize and uphold these natural rights.

It would follow, then, that anyone ingenuous enough to go to the moon and collect a handful of dirt more than deserves to own it—and that government must support their initiative. Whatever you think of Locke’s theory, it’s certainly more convincing (or at least less offensive) in a lunar context than in, say, a colonial one.**

The thing is, in our world (and pretty far outside it, apparently) the notion of a natural right preceding or not preceding government doesn’t really matter. Private ownership of all things depends less on some nice idea about laboriously cultivating fruits on unclaimed land than on an international system built on defining and protecting existing property rights.

At the risk of sounding tautological (and, you know, crudely oversimplifying all of capitalism): we own stuff because that stuff is recognized as ours by our government(s), and governments recognize each other because of their mutual recognition of our legitimate ownership of that stuff.

There are variations by jurisdiction, naturally. For example, it’s illegal in many countries to own endangered species: neither the state nor its courts will not defend your right to keep a panda in your basement, even if you found or caught or against all odds bred the panda yourself. Queen Elizabeth owns all the unmarked mute swans in England, and Brexit or no Brexit, you couldn’t buy one if you tried. You can’t even own a house in much of North Korea. But quirks aside, states recognizing other states’ laws over property is an essential basis for world trade.

NASA’s mandate is not world trade. It’s outer space, and increasingly, outer space trade. But by applying the (earthly) logic of private property to the moon and other planets, they are trying to create a market where there is none. (This example also shows how much private enterprise, even at the cutting edge of technology and human civilization, depends on incentives from governments—but that’s a different story!)

It’s not often that we get to observe the wheels of capitalism turning quite so transparently, with remarkably little euphemism or abstraction or spin. This is literally how markets get made. And while there is much to be wary of here, I still find Jim Bridenstine’s statement oddly poignant. It’s a reminder that our world is not inevitable, but rather, crafted one request for proposals, one piddling government contract, one official press release, one email newsletter at a time.

The low price of the moon dust belies the high stakes of the operation: over our lifetimes, we may watch its price climb higher and higher, before transmogrifying into some dizzying asset-backed security—a future of the future. But for now, it’s just dust, and it’s cheap, and somebody is going to go to space and put it in a box and bring it back to earth and remember, if only for a moment, that it is alien.

*can of worms, much?

**further out in space is another question, particularly if you believe, as I think I do, that we are not alone in the universe.

Share

After a weekslong pressure campaign by my husband, I finally watched Christopher Nolan’s new movie. It brings me no pleasure to report that I didn’t really understand it, either. 

The film follows our unnamed agent/hero (John David Washington) and his sidekick, Neil (Robert Pattinson) on a mission to stop Satar, an evil Russian played by Kenneth Branagh, from destroying the world. The plot centers around Satar’s access to “inverted objects”, which can travel through time backwards and pose an existential threat to humanity if they take the form of bullets or nukes (spoiler: they do.) There are car chases, gunfights, an art forgery, a very tall and tragic wife, and loads of confusing dialogue. I don’t really care for all that stuff, but what was interesting to me was how the action in the movie takes place almost entirely offshore: in yachts, offshore wind farms, and notably, freeports in Oslo and Tallinn.

At the beginning of the film, Washington and Pattison break into the Oslo facility by getting a buddy to drive an airplane into it (as is often the case, the warehouse is adjacent to the airport). At its climax, our heroes return to the storage facility and fight versions of themselves at different points in time. Along the way, minor characters come and go from Satar’s yacht anchored off the Amalfi coast, and Washington does pullups inside an aquatic wind turbine, shedding his former self in kind of liminal state while he waits for his next mission.

These types of locales are easy ways to visually represent the lifestyles of the ultra-rich. But it’s time that’s central here, not just to the movie but to the concept of the freeport, and the very functioning of the offshore world.

Share

In the broadest sense, freeports are warehouses or gated areas where certain tax and customs duties don’t apply. They are what academics call “onshore offshore”: spaces that geographically are within a country’s borders, but for the purposes of customs, are considered beyond them. Dara Orenstein, the author of an excellent new book on the subject, likens them “gated communities for capital.”

The specifics vary by jurisdiction, time period, and contents, but for the sake of dissecting this already-complicated movie, just assume that the model for Nolan’s movie is something like Luxembourg’s Le Freeport.

Here’s how it describes its function:

LE FREEPORT | Luxembourg is a fully integrated facility, where functional design meets technological excellence. It is the world’s safest storage and trading platform for your valuables.

LE FREEPORT sets new standards, demanded by investors and collectors alike: a purpose built facility combining cutting edge technology, efficient logistics as well a large spectrum of services and expertise.

LE FREEPORT is the ideal platform for securing, servicing and preserving works of art and other valuables.

Christopher Nolan could not have done a better job of muddling what the facility actually does, which is really quite simple: it stores expensive art, wines, cars, etc. risk- and tax-free until they are ready for their next destination, be it someone’s living room, a museum, or another cubby down the hall in the same freeport. There used to be a lot of intrigue around these places, but regulation has improved somewhat over the past decade to prevent things like illegally-acquired artworks from being hidden away. It’s important to note that these aren’t lawless spaces. They are state-sanctioned to the max. Still, the way these warehouses permit and even encourage rich people to buy and sell art without incurring sales or customs tax, along with the fact that they put some of the world’s greatest artworks in essentially a black box, have drawn persistent and legitimate critiques that the industry tries very hard to counter.

The movie gets the industry spin just right. In an early scene, Washington and Pattinson take a tour of the Oslo facility with a young man who, in hushed tones, assures them that there is nothing shady going on here—it’s about security. “Our clients choose us because we have no priority beyond their property,” the man says.

This was almost word for word what I was told when reporting on Arcis, a similar facility in Harlem, a couple of years ago (Arcis is now closed.) To get in, you had to get your irises scanned. The generator had backup generators. Every item was accounted for with the company’s proprietary software. It felt like a place out of time.

Another point that people in this business insist upon is that the facilities are not a way to avoid taxes, but merely to suspend them. From Le Freeport’s “Misconceptions” section on their website**:

“Just like in thousands of bonded warehouses under customs supervision, there is naturally no general exoneration of taxes, but rather a mere SUSPENSION of the local consumption tax (VAT) and of the (possible) Customs duties, for as long as the goods are stored at LE FREEPORT.”

This is true; in fact, it’s in the freeport’s DNA. Hundreds of years ago, freeports were located in actual ports, and featured silos so that grain and other perishables could be stored for a few nights while ships docked, restocked and changed crew. The rub in 17th century Livorno was that grain could go bad; it could not languish in storage forever without losing its value. But in climate-controlled and ultra-secure environment in 2020, luxury goods can remain intact forever. That’s the whole pitch!

There is, then, not much preventing a painting from being bought, sold, and bought, and sold forever inside the four walls of the freeport, thereby avoiding various taxes indefinitely. Some freeports even have galleries to show art to prospective buyers inside the warehouse, and outside of national space and time.

This very real and practical suspension of time that freeports engage in daily is why they’re a brilliant setting for a big action movie about time-travel. Because if we accept that time is to some degree a construct, it makes sense that those in power will manipulate it to their advantage. In the real world, the government wields this power by allowing freeports to “suspend” taxes, but also by doing things like making us suffer through daylight savings time. In the universe of Nolan’s action movie, this power is instead concentrated in an “inverted object”, controlled by its owner, who can dictate its course.

I can’t guarantee to you that Nolan thought this hard about these things… but since this is a movie that lends itself to endless online prognosticating, I want to share one more detail that suggests he did.

In the U.S, the vast majority of “freeports” are actually called foreign trade zones and they are used for boring things like manufacturing lawn mowers, not storing Picassos. FTZs, too, are a kind of time/tax hack.

When the government imposes tariffs on the import of raw materials, like steel, but not on the import of a finished product, like a lawn mower, companies might bring the steel into the free zone, manufacture the product, then import it. During manufacturing in the zone, the steel exists “outside” of ordinary American time and space in a suspended, liminal state for the purposes of customs. It is the finished lawn mower that ultimately enters the U.S space-time continuum; and, being a lawn mower, it incurs (lower or non-existent) lawn mower tariffs instead of the fees on its component parts.

This mechanism has a most curious name. It’s called an inverted tariff.

*Not really

**Why, you might be thinking, does an innocent warehouse need a MISCONCEPTIONS tab on its website?

The Doctor. Luke Fildes, 1891.

This past semester, I took an anthropology class (on Zoom) about the concept of sovereignty: who has it, what it looks like, how it’s changed, and how it endures over time. Throughout human history, there’s pretty much always been something out there that represents to people a kind of supreme authority—whether it’s a single deity or a bunch of supernatural animal/mineral/vegetable spirits. It hasn’t always been bound by territory, and it certainly hasn’t always depended on a centralized state—these are relatively recent and Western concepts—but it’s been there in some form or another. Make of that what you will.

Today, we tend to think of sovereignty as the power that countries exert over their land and what’s on it. That includes the power to keep people out, let people in, detain people, wage war, issue currency, and write laws. Practically speaking, in December 2020, sovereignty also means holding the power to inoculate people against COVID-19: a supreme authority if there ever was one.

As far as I can tell, access to the vaccine remains, for now, firmly in the hands of individual states. They have struck deals with pharmaceutical companies either directly or through a supranational body like the World Health Organization to acquire doses for their population. They have decided, or are deciding, who will get the vaccine first. And as more and more drugs become available, states will be in charge of scaling up the inoculation process: again, partnering with a pharmacy chain or network of medical professionals, or doing it through their national health service, which sounds like a pretty nice thing to have. 

If you’re an average healthy youngish person in a wealthy country, you’ll probably get your shots by next summer. If you live in a poorer nation, you might not be so lucky. That also means your country probably won’t re-open as fast, its most vulnerable people will keep dying, and the cycle of inequality, death and destruction will keep pace. 

So there is absolutely nothing surprising about the spate of recent stories telling us that rich countries have bought up all the available doses and are even hoarding more than they can use. It’s also not news: anyone with half a brain cell saw this playing out from day 1 of the lockdown. Remember when all of downtown Manhattan went dark during superstorm Sandy but the lights at Goldman Sachs stayed on? We’ll get a version of that, but on a global scale as well as a national one.

It’s not yet clear if there will be additional options for citizens of one country living in another; it will probably depend on the countries. The U.N, which employs a large number of expats, issued a notice in November saying that while the “host” country should take the lead, it “recommends the creation of a small central stock to be strategically pre-positioned to meet the COVID vaccine requirements of UNCTs/UN Missions whose host country will be unable to meet their duty of care towards their UN population.” Translation: if you’re a peacekeeper in a supremely poor country with few resources, or an elderly assistant secretary-general in New York City, we’ve got your back. The rest of you, get in line. 

There’s also the possibility of states extending their vaccination drives beyond their borders. Being Swiss and Canadian and living in a country that has hardly inspired confidence throughout the course of the pandemic, I have a personal interest in this. I’m counting less on Canada, whose healthcare system is organized by province, and more on the Swiss, who are masters of disaster preparedness (my husband makes fun of me when I say the Swiss will show up at our door in a helicopter if/when the shit hits the fan, but I’m only half joking.) In any event, whether I’m in New York City or Geneva or Vancouver, I will probably be one of the last people to get it, and that’s how it should be.

What I’m currently obsessing over is what small, rich countries will do with a surplus once it is in their possession. In the best of worlds, they would donate it to poor countries, who will in turn give it to those who need it the most. But in our world—and, disclaimer, this is a bald projection based on a cynical hunch based on years of reporting experience—effective national monopolies over the COVID-19 vaccine could easily turn into a money-making enterprise not unlike previous attempts at commercializing state sovereignty. 

In other words: states could easily use their ability to acquire and distribute the vaccine to benefit the wealthiest foreigners.

You can easily imagine a Switzerland or a Singapore buying (or manufacturing) a surplus of doses; efficiently and swiftly vaccinating everybody who resides within their borders in order to re-open their economy; and then getting into the business of offering COVID-19 vaccines to foreigners with enough money to a) pay for the shots and b) spend a couple of months between injections in the country, possibly under quarantine. You might package this offering up as a spa vacation in the Alps, or a wellness package at the Marina Bay Sands. I also see countries bundling residence or citizenship with access to “health” or “insurance” services—code for a Covid-19 vaccine?—or even letting consuls around the world give out shots for money. The more you think about it, the more dystopian it gets; all I’m saying is that these hypothetical practices aren’t so far off what countries already do.

Now, I don’t believe this possible future is necessarily a worse one than if private enterprise controlled the vaccinations. There are unthinkably unjust downsides to that, too. But I do think this scenario illustrates how the qualities and powers of a sovereign—the things you can only do if you are an independent country—lend themselves to money-making, and ultimately constitute a kind of market of their own. 

Island nations used to sell postage stamps or lease area codes to phone-sex operators to make an extra buck: their state sovereignty gave them a monopoly over these utilities, and they saw little downside to meeting demand from philatelists and pornographers. Countries then got into the business of selling passports to rich people, or slashing taxes for corporations: somewhat less whimsical variations on the same theme.

This leads us to 2020 (or should I say, #2020): when the confluence of globalization, medical tourism and inequality in a pandemic gives countries the power not just to “make live and let die” to borrow a phrase from Michel Foucault (can you tell I’ve been taking a class at Harvard!?) but to potentially make money off of the decision. As per usual, some states will prove themselves to be more sovereign than others.